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The assessee has filed complete details of unaccounted sales, as per seized material, at Rs 1,33,38,002 and the Assessing Officer, vide letter dated 14th March 2014, has disputed it as incorrect without giving any other details or the correct details on his own. When Assessing Officer rejects the factual aspects, clearly based on the impounded material, it cannot be open to him to reject the same without giving specific details and cogent material in support of his alternative stand. The very approach adopted by the Assessing Officer is in violation of the fundamental principles of natural justice and unsupported by any facts on record. 

Shanti Prime Publication Pvt. Ltd.

Section 145 of the Income Tax Act, 1961— Method of Accounting—Impugned addition to be deleted where pursuant to survey proceedings, AO made addition to assessee's income on basis of estimated gross profit on sales in view of fact that AO had rejected assessee's books of account without giving any specific details and moreover, there was decline of only 1.04 percent in rate of gross profit in relevant year for which assessee had given detailed explanation— Mayankkumar Natwarlal Soni vs. Additional Commissioner of income tax [2019] 179 ITD 444 (Ahmedabad-trib)   

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